AQ_F_0900009_20190325_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Chemours Company-Fayetteville Works
NC Facility ID 0900009
Inspection Report County/FIPS: Bladen/017
Date: 05/09/2019
Facility Data Permit Data
Chemours Company-Fayetteville Works Permit 03735/T44
22828 NC Highway 87 West Issued 3/14/2019
Fayetteville,NC 28306 Expires 3/31/2021
Lat: 34d 50.6700m Long: 78d 49.8750m Class/Status Title V
SIC: 2869/Industrial Organic Chemicals,nec Permit Status Active
NAICS: 32512/Industrial Gas Manufacturing Current Permit Application(s)TV-
Administrative,TV-Sign-501(b)(2)Part I,
Contact Data TV-Sign-501(b)(2)Part II
Facility Contact Authorized Contact Technical Contact Program Applicability
Christel Compton Brian Long Christel Compton SIP/Title V/112r
Program Manager Plant Manager Program Manager MACT Part 63: Subpart Boiler-112j, Subpart
[phone] [phone] [phone] FFFF, Subpart ZZZZ
NSPS: Subpart Dc
Compliance Data
Comments: eDL
Inspection Date 03/25/2019
Inspector's Name Gregory Reeves
Inspector's Signature: .:a? ( Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature: pslp9/Iq/y On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2017 3.97 0.2000 61.63 239.09 33.86 3.97 34586.00
2016 4.16 0.2100 65.19 237.76 36.45 4.16 36881.00
2015 8.94 0.2030 55.45 290.39 42.10 8.94 34123.00
*Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
03/01/2019 Pending

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 2 of 7
1. DIRECTIONS TO SITE:
Chemours Company-Fayetteville Works is located on NC Highway 87 in Bladen County. From FRO,take
Highway 87 south. The entrance to the facility is approximately 18 miles from FRO on the left side of
Highway 87 just before the Cumberland/Bladen County line.
2. SAFETY CONSIDERATIONS:
The usual FRO safety gear is required(hardhat, safety glasses,safety shoes,hearing protection). Entry into
several areas of the plant requires specialized safety gear. In the HFPO reactor and MMF process areas,
personnel are not allowed to enter unless the process is not operating due to the possibility of explosion hazards
of the chemical reaction process.
3. FACILITY DESCRIPTION:
Chemours Company-Fayetteville Works is a chemical manufacturing facility located in Bladen County. The
facility was formerly owned by DuPont. The facility employs approximately 500 employees and 250 full-time
contractors on a 24 hr,7 days per week basis. The facility consists of four individual manufacturing plants, a
boiler house and a waste treatment operation. Several processes have PSD avoidance conditions. The facility
has two permanent boilers onsite, one permanent boiler which is permitted but not yet constructed,and one
permitted temporary boiler.
4. INSPECTION SUMMARY:
On Thursday,February 21,2019, 1,Greg Reeves,of the DAQ Fayetteville Regional Office,met with Dianne
Fields, Sr.Manufacturing Engineer,for a partial inspection of the facility's enhanced LDAR program as
proposed by Chemours as a result of the"Third-Party LDAR Program Review"performed by ERM NC,Inc. on
January 31,2018 and submitted by Chemours to DAQ in an email correspondence from Christel Compton on
January 31,2018. The inspection focused solely on the facility's LDAR program as related to the uncontrolled
fugitive leaks from process equipment and piping located outside buildings at the PPA,VE South,VE North,
and SemiWorks processes that contain materials which have concentrations of the"GenX"compounds(HYPO
Dimer Acid,HFPO Dimer Acid Fluoride,and the ammonium salt form of these)greater than or equal to I
percent. I did not delve further into any of the other changes made under the enhanced LDAR program.
5. BACKGROUND:
The facility contracted with ERM to review the then-current Leak Detection and Repair(LDAR)program for
possible improvements in order to further reduce fugitive emissions of GenX compounds from pumps,valves,
and connectors in processes that contain materials that have concentrations of these compounds greater than
1%.by weight. ERM submitted this"Third Party LDAR Program Review"report to the facility on January 31,
2018. Recommendations from the report were incorporated into the facility's LDAR program that is conducted
under the requirements of NESHAP Subparts FFFF and UU in the current permit. Note that the NESHAP
requirements are intended to control HAP. Currently,the GenX compounds are not included in the list of HAP
materials under the NESHAP,but are the subject of further investigations by DEQ and will be further controlled
with additional emission controls under the newly issued air permit 03735T44.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 3 of 7
Proposed improvements recommended by the ERM report and facility implementation of these
recommendations included the following:
1. Indoor Fugitive Leaks Installation of GAC systems is proceeding. (NOTE: N
The GAC systems have now been installed at PPA and
VE North and will be installed at VE South)
2. Pressure Testing The facility will begin to use one or the other of the
recommended options for pressure testing and will
maintain formal documentation of the testing by
2/16/18. (NOTE: The facility was already conducting
pressure testing prior to startup of these processes. The
facility has implemented procedures to use more
stringent pressure drop criteria for these initial tests to
improve the integrity of the systems and reduce leaks.)
3. Enhanced AVO Inspections The facility will implement the recommended procedure
by 2/16/18. It will also further evaluate the capabilities
and compatibility of an ultrasonic leak detector in
evaluating for leaks in the applicable units.
4. Additional Method 21 Instrument The facility plans to conduct an experimental evaluation
Monitoring by 3/3/18 to verify that the TVA-I00013 would detect
vapors of DAF. If the TVA sufficiently responds to
HFPA-DA and HFPO-DAF the facility plans to
implement the use of the TVA-100013 as soon thereafter
as practicable. (NOTE: The TVA-100013 was deemed
able to detect these vapors and has been incorporated
into the LDAR program for the GenX compounds)
5. Enhanced Area Monitoring The facility will conduct an evaluation of the preferred
method to implement this recommendation by 3/3/18
and will implement in accordance with the
recommendations from the evaluation. (NOTE: The
enhanced area monitoring was implemented starting in
April 2018. This included reduced intervals between the
LDAR scans conducted by the contractor[TEAM
Furmanite, Inc] who performs the leaks scans)
6. Replacement or Improvement Options for The facility will conduct an evaluation of the preferred
Valves and Connectors methods to implement these recommendations by 3/3/18
and will implement those methods as soon thereafter as
practicable. In the interim,the facility will look for
opportunities to increase the utilization of low emission
replacement valves and connectors. (NOTE: This is an
ongoing project,mostly conducted during periods of
shutdown of the related processes.)

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 4 of 7
The facility utilizes a consultant(TEAM Furmanite,Inc)to perform the periodic LDAR scans in the various
operating areas. The requirements under the NESHAP Subpart FFFF and UU regulations are as follows:
Equipment Tye Pumps Valves Connectors
Concentration that 2,000 ppm 500 ppm 500 ppm
determines a"leak"
Frequency of Scans Monthly visual scan 1. Initial Scan 1. Initial Scan
2. If initial scan shows 2. If>0.5%of
up to 2 leaks or<2% connectors show
of valves show leaks, leaks,then subsequent
then subsequent scans scans are annually
are monthly. 3. If>0.25%but<0.5%
3. If<1%of valves show of connectors show
-- leaks,then subsequent leaks,then subsequent
scans are semi-annual scans are every 4
4. If<0.5%of valves years.
show leaks,then 4. The facility is
subsequent scans are required to re-monitor
annually leaking connectors
5. If<0.25%of valves within 90 days after
show leaks,then repairs are made
subsequent scans are
biennial
The"enhanced"LDAR requirements adopted by the facility are as follows:
Equipment Type Pumps Valves Connectors
Concentration that 1,000 ppm 100 ppm 100 ppm
determines a"leak"
Frequency of Scans Monthly visual scan 1. Initial Scan 1. Initial Scan
2. Subsequent scans are 2. The facility is
conducted quarterly required to re-monitor
leaking connectors
within 90 days after
repairs are made
3. Subsequent scans will
be conducted yearly
6. INSPECTION FINDINGS:
I reviewed with Ms.Fields the computer records of the specific LDAR scans made during the months of April,
May,August,and November 2018,and for February 2019. 1 only reviewed the LDAR records for those
components identified for the Enhanced LDAR program as proposed in January 2018. The April 2018 scans for
VE North,PPA,and SemiWorks were considered the initial scans, and included both valves and connectors in
the areas outside the emissions-controlled buildings. The May 2018 scans for VE South were considered the
initial scans and included both valves and connectors. Scans of valves subsequent to the initial scans were
conducted quarterly, as no fugitive emissions were detected above the 100 ppm"leak"threshold during any of
the initial scans. The quarterly scans are conducted much more frequently than what is required under the
NESHAP Subpart FFFF and UU regulations for this group of equipment.
Scans consist of Method 21 readings using a Flame Ionization Detector(currently using a ThermoFisher TVA-
100013 FID). A background reading is taken for each sample point,then the component sample point is tested.
A"net'emission value is calculated by subtracting the background reading from the component sample point
reading. This"net'value is used to determine whether a`leak"is detected compared to the concentrations
listed in the tables above that constitute a leak. Any further action is determined by that net value.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 5 of 7
Results of the scans are as follows(All items in the areas monitored in these tables contain>1%by weight of
the GenX compounds—other components in the process are monitored on the frequency dictated by the
NESHAP Subparts FFFF and UU regulations):
VINYL ETHERS NORTH PROCESS AREA:
April 2018
(Initial Scan) 64 162 1-2 212 14
(Valves and (all 1 ppm)
Connectors)
May 2018 50
(Valves only) 64 0 2 14 (varied from 1-2 ppm)
August 2018 64
(Valves only) 64 0 1 0 (varied from 2-4 ppm)
November 2018 3
(Valves only) 64 0 2 61 (varied from 1-2 pm)
64
February 2019 64 0 0 0 (varied from 2-12 ppm)
(Valves only) (1@l2ppm, 1@8 ppm,
2 7 ppm)
VINYL ETHERS SOUTH PROCESS AREA:
d
ryt A `dn
7 x e 44TnlectbrS
May 2018 26
(Initial Scan) 7 19 1 0 (all 1 ppm)
(Valves only)
August 2018 4
(Valves only) 7 0 3 3 (varied from 1-2 m)
November 2018 7 0 2 7 0
(Valves only)
6
February 2019 7 0 1-2 1 (varied from 2-7 ppm)
(Valves only) (1 P7ppm, 1 @4 ppm)

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 6 of 7
POLYMER PROCESSING AID(PPA)PROCESS AREA:
All k 6 d"
Rgj�i No '11 ­ �5Q I � i� i0th
I !_ kdf ni's
j 11 I
po-�
K" cb'j 01-1 1
wecto ? I
of
April 2018
(Initial Scan) 28 69 3-4 92 5
(Valves and (1-2 ppm)
Connectors)
May 2018 1
(Initial Scan) 28 0 1 27 (2 ppm)
(Valves only)
August 2018 28 0 2 2 26
(Valves only) (varied from 1-2 ppm)
November 2018 28 0 0-1 10 18
(Valves only) (varied from 1-2 ppm)
February 2019 28 0 2-3 27 1
(Valves only) (I ppm)
SEMIWORKS PROCESS AREA:
611 0 1
F it :1� �4
! p-"'
in 4 g
April 2018
(Initial Scan) 10 61 2 32 39
(Valves and (38@1 ppm, 1@18 ppm))
Connectors)
May 2018 10
(Initial Scan) 10 0 2 0 (1-5 ppm)
(Valves only) (1 @5 ppm, 9@ 1 ppm)
August 2018 10 0 2 2 8
(Valves only) (all 1 ppm)
November 2018 10 0 2 10 0
(Valves only)
February 2019 10 0 2 10 0
(Valves only)
7. CONCLUSIONS AND RECOMMENDATIONS:
In review of the January 2018 Third Party LDAR Program Review conducted by ERM,the report listed the
number of various outdoor components(valves,connectors, and pumps)that were in each of the four operating
areas that were associated with fluids containing greater than I%by weight of the GenX chemicals. The
numbers of components identified in this review do not correlate with the number of components that were
included in the actual facility program for the enhanced LDAR program. For example,in the VE North
operating area,ERM identified 114 valves,295 connectors,and I pump associated with fluids with greater than
I%by weight of GenX chemicals. However,the facility records indicate that the enhanced LDAR scans only
included 64 valves and 162 connectors,and no pumps.
I requested additional information on these apparent differences from Dianne Fields at the facility. An initial
response received via email indicated that these discrepancies in component counts was due to ERM using
counts from P&IDs versus the current components field-verified in the plant. I have requested additional
clarification of these counts.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 7 of 7
Update 05/02/19—Greg Reeves received an email from Dianne Fields that explained the differences in the
component count between what is actually included in the quarterly Enhanced LDAR scans and what was
identified in the original ERM program review. It appears that the ERM review relied on facility P&ID
diagrams,which do not indicate which components are located inside buildings. Therefore,their review
included many components that are inside buildings and are already controlled by various control devices. The
actual quarterly scan listings have been field-verified versus the P&IDs to include only those components
located outside the buildings and have no controls.
It appears that the facility is following the proposed Enhanced LDAR program which was proposed in January
2018.
It appears that the Enhanced LDAR program that was initiated in April/May of 2018 is demonstrating that very
few leaks are occurring in the target components. It was not clear what actions, if any,are taken by the facility
to follow up on components that show net readings that are significantly above the average for the area(such as
the 18 ppm net reading in SemiWorks in April 2018 versus other components at 1 ppm)but are still below the
"leak"threshold of 100 ppm. All of the readings are below the"leak"definition of 100 ppm set in the program.
However, if there are higher ppm outliers in the scans, I would expect the facility to address these in some way
given the high public profile of the GenX emissions.